ML20132G223

Forwards Safety Insp Rept 50-443/85-20 on 850708-0827 & Notice of Violation.Concerns Over Administrative,Engineering & Const Controls Which Allowed Incomplete & Incorrect Work to Be Installed Remain

ML20132G223
Person / Time
Site:	Seabrook
Issue date:	09/18/1985
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Harrison R PUBLIC SERVICE CO. OF NEW HAMPSHIRE
Shared Package
ML20132G227	List: IR 05000443/1985020 IR 05000708/2008027 ML20132G223
References
NUDOCS 8510010502
Download: ML20132G223 (2)

See also: IR 05000443/1985020

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SEP 181985

Docket No. 50-443

'Public Service Company of New Hampshire.

ATTN: Mr. Robert J. Harrison

President and Chief Executive Officer

P.O. Box 330

Manchester, New Hampshire 03105

Gentlemen:

Subject: Inspection No. 50-443/85-20

This refers to the routine safety inspection conducted by Mr. A. Cerne and other

inspectors of this office on July 8 - August 27, 1985 of activities authorized

by NRC License No. CPPR-135 and to the discussions of our findings held by Mr.

Cerne with Mr. Guillette and others of your staff at the conclusion of the

inspection.

Areas examined during this inspection are described in the NRC Region I In-

spection Report which is enclosed with this letter. Within these areas, the

inspection consisted of selective examinations of procedures and representative

records, interviews with personnel, and observations by the inspector.

Based on the results of this inspection, it appears that certain of your activi-

ties were not conducted in full compliance with NRC requirements as set forth

in the Notice of Violation, enclosed herewith as Appendix A. These violations,

have been categorized by severity level in'accordance with the NRC Enforcement

Policy (10 CFR 2, Appendix C) published in the Federal Register Notice (49 FR

8583) dated March 8, 1984. Your are required to respond to this letter and in

preparing your response, you should follow the instructions in Appendix A.

Item B in the Notice of Violation enclosed with this letter identifies a failure

in your corrective action program relative to a construction deficiency reported

under 10 CFR 50.55(e). It is noted that Item A also relates to a potential

50.55(e) deficiency, subsequently withdrawn as a reportable deficiency, and an

apparent problem in effecting corrective action by way of design change detail

implementation. While the adequacy of corrective measure controls has not been

a problem in the recent past of Seabrook construction, the details of both

violations and their apparent causes are of some concern because they both

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portend the potential for administrative weaknesses leading to uncorrected

hardware deficiencies. Another common element in both violations appears to be

an'over-reliance on your QA/QC program to remedy problems in your design change

control and inter-organizational communication channels. We trust that you will

i agree that regardless of whether the work procedures and in process records

i correctly characterize the work as safety-related or not, installation in

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accordance with the approved design details is expected.

8510010502 850918 3

DR ADOCK O

0FFICIAL RECORD COPY

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Public Service Company of 2

New Hampshire

We note that your letter (SBN-835) to Region I on July 10, 1985 provided

clarification of your Final Report on the construction deficiency involving the

diesel generator exhaust silencer pedestal cracking. While the hardware problems

may not be fully corrected on this issue, as well as the limit switch bracket

support problem, our concerns over the administrative, engineering, and con-

struction controls which allowed incomplete and incorrect work to be installed

remain. Consequently, your response to the Notice of Violation should include a

discussion of not only your improved controls in these areas, but also your

program for uti'i?.ing QA requirements for assuring, rather than implementing,

quality work.

The responses directed by this letter and the accompanying Notice are nc: subject

to the clearance procedures of the Office of Management and Budget as ieqJired

by the Paperwork Reduction Act of 1980, PL 96-511.

Your cooperation with us in this matter is appreciated.

Sincerely,

Orisinat::c m vp

Samuel J. Collins, Chief

Projects Branch 2, Division of

Reactor Projects

Enclosures:

.1. Appendix A, Notice of Violation

2. NRC Region I, Inspection Report No. 50-443/85-20

cc w/ encl:

John DeVincentis, Director, Engineering and Licensing

William B. Derrickson, Senior Vice President

Warren Hall, Operational Services Supervisor

Donald E. Moody, Station Manager - Seabrook Station

Gerald F. Mcdonald, Construction QA Manager

Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

State of New Hampshire

bcc w/ encl:

Region I Docket Room (with concurrences)

Senior Operations' Officer (w/o encis)

DRP Section Chief

J. Grant, DRP

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